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amount. The payment was accompanied by a payment voucher
indicating that the payment was for Astrid Downing’s and
petitioner’s 1995 joint account. The payment voucher lists
Astrid Downing as the primary taxpayer and petitioner as spouse.
Respondent’s transcript indicates that the $8,728 payment was
posted to Astrid Downing’s 1995 account as a “PAYMENT WITH
RETURN”.
2001 Correspondence About 1995 Returns
By notice dated March 12, 2001, and addressed to petitioner,
respondent indicated that petitioner had not filed his 1995
return and requested petitioner to provide information.
Petitioner responded by letter dated April 11, 2001, stating that
he had been living and working in Singapore in 1995 and that
Ernst & Young “was responsible for my tax returns.” He stated
that “my 1995 return” had been “done and submitted by” Ernst &
Young and that an amended return had also been filed. The letter
stated that petitioner was enclosing both returns. Included with
the letter were: (1) An unsigned copy of the previously
described 1995 married filing separate return for petitioner; and
(2) a copy of the previously described 1995 joint amended return
for petitioner and Astrid Downing, unsigned except for the
signature of petitioner’s tax return preparer, dated October 15,
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